BROWN, J.
We quote from the memorandum opinion of the trial judge:
"The material allegations of the complaint, with the paragraphs in which they are to be found indicated, are as follows:
"(3) Suburban Builders, Inc., is a Wisconsin corporation, organized September 20, 1945, and still in existence and doing business.
"(4) On August 16, 1949, the Wisconsin department of taxation made an income-tax assessment against Suburban Builders, Inc.,...
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